MEMORANDUM

DISCUSSION:

The purpose of this memo is to remind staff of the process for serving customers who are limited English proficient (LEP).

Title VI of the Civil Rights Act of 1964, as amended, directs that health and social service providers who receive federal financial assistance from the Department of Health and Human Services have an obligation to ensure individuals who are limited English proficient (LEP) have meaningful and equal access to benefits and services. In order to comply with Title VI, Family Support Division (FSD) staff will ensure that LEP persons are not:

• Required to find their own interpreter;
• Denied basic information about benefits and services for which they are eligible;
• Turned away from applying for or requesting services;
• Forced to wait for long periods of time before effective communication can occur; or
• Required to make repeated visits to offices until an interpreter is available.

To ensure that LEP persons have meaningful and equal access to services, FSD staff will use:

• Contracted interpreters for oral communication;
• Contracted translators for document translations; and
• Spanish versions of FSD forms when appropriate.

FSD staff will not:

• Provide translations in lieu of using contracted interpreters.
• Rely on the LEP person's friends or family or other untrained interpreters to provide interpretation services.

Such acts may be found to be in violation of Title VI of the Civil Rights Act of 1964, as amended.

Telephone Interpretative Services

Language Select has a statewide contract to provide FSD with over–the–telephone foreign language interpretation. Language Select provides a three–way–call service that can be used:

• When an LEP person calls a FSD office;
• When FSD staff call an LEP person; and
• When an LEP person visits a FSD office.

  NOTE: The Language Select service is to be used for official FSD business only. By contract, Language Select abides by state confidentiality requirements similar to those practiced by FSD personnel.

For instructions on using the Language Select service, FSD staff will refer to procedures outlined in the Language Select How to Use guide located on the FSD Intranet in the Quick Links.

In-person Interpretive Services

Office of Administration (OA) maintains a listing of several contracts for in–person interpretation. These contracts can be found by accessing OA's Internet web site http://www.oa.mo.gov/purch/contracts/index.htm, enter "interpreter" in the "Search by Keyword" box and click on "Submit."

When FSD staff needs an in–person interpreter, (s)he or her/his office designee will:

• Select any three of the available contractors.
• Call each of the three contractors to obtain price quotes. The staff member or designee should be specific as to the language, situation and anticipated time the interpreter is needed.
• Obtain supervisory approval to proceed with the lowest–priced bid that meets the FSD's needs for an in–person interpreter.
• Contact the approved contractor to proceed with scheduling the in–person interpreter.
• The contractor will send an invoice for the work to the FSD field office. Each office is locally responsible for paying for any in-person translations.

  NOTE: By contract, these vendors abide by state confidentiality requirements similar to those practiced by FSD staff.

Written Translation Services

FSD staff must use Global Languages & Cultures Inc for all written translation services. Their contact information is as follows:

Global Languages & Cultures Inc.
70 East Lake Street #1116
Chicago IL  60601-7552
Attn:  Georgeanne Van
Phone:  312-456-0654
Fax:  312-456-0656
Email:  Georgeanne@e-translation.com

When written translation service is necessary, contact Global Languages & Cultures Inc. by telephone, fax or email. All requests should go through appropriate supervisory channels. Each office is locally responsible for paying for any written translations.

Several FSD forms are available in Spanish and may be used as appropriate. These documents are available in the IM Forms Manual Volume I and II on the Intranet:

FS-1 (Spanish) Application for Food Stamp Benefits in Spanish
IM-1CC (Spanish) Child Care Application in Spanish
IM-2 Mod (Spanish) Eligibility Reinvestigation in Spanish
IM-2 Mod Adult (Spanish) Adult Supplement in Spanish
IM-2C (Spanish) Expenses of Producing Income in Spanish
IM-3A (Spanish) Reinvestigation Notice in Spanish
IM-4EBT (Spanish) EBT Information Pamphlet – Spanish
IM-4 (Hearings - Spanish) Hearing Rights in Spanish
IM-31A (Spanish) Request for Information in Spanish
IM-31A MC+ (Spanish) MC+ Request for Information in Spanish
IM-31F (Spanish) Instructions for Making Your Food Stamp Application/Food Stamp Rights (in Spanish)
IM-32 (Spanish) Approval Notice in Spanish
IM-62 (Spanish) Notice of Eligibility for Nursing Facility/Other Vendor
IM-82A (Spanish) Notice of Vendor Termination
IM-90 (Spanish) Withdrawal of Request for Hearing
IM-214 (Spanish) Affidavit for Replacement Check
IM-215 (Spanish) Affidavit of Forgery

Internet Applications Available in Spanish and Other Languages

The Application for Food Stamp Benefits form is available in Spanish as a portable document format (.pdf) on the DSS Internet site. The Electronic Benefits Transfer pamphlet and Important Information about Your Hearing Rights brochure are available in Spanish.

The Missouri Food Stamp Pre-screening Eligibility Tool is an on-line service for potential applicants to pre-screen for Food Stamp eligibility in Spanish.

The Family Support Division Program Enrollment (formerly the Missouri Benefits Center) on the DSS Internet site allows individuals to apply for Food Stamps, MO HealthNet for Families, Kids, and/or Pregnant Women, to review their benefits and report changes. These Internet services are all available in Spanish.

The MO HealthNet for Families, Kids, and Pregnant Women  instructions and application form is available in Spanish, Bosnian, and Vietnamese as a .pdf on the DSS Internet site.

Other Services in Spanish

The Family Support Division Information Center (FSD INFO Center) at 855-373-4636 is the call center for the FSD Income Maintenance programs. Customer Service Representatives (CSRs) have been trained to answer questions regarding IM programs, and limited case specific questions. CSRs do not answer eligibility questions. Specific questions regarding Food Stamps are routed to a call-center merit employee. The FSD INFO Center CSRs use a contracted interpretive service for callers who are LEP.

When the caller needs more information than the CSR can provide, an email will be generated to the local FSD email address. The FSD INFO Center will include information on the customer's need for interpretive services in any email to field staff, so arrangements can be made with Language Select for an interpreter before field staff returns the customer's call.

The Missouri EBT (electronic benefit transfer) Customer Service Line at 800-997-7777 provides services in Spanish.

The MO HealthNet Participant Handbook is available in Spanish on the DSS Internet site. The MO HealthNet Division's Managed Care Health Plans also provide non-English language handbooks and interpretative services.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

JM